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2011-05-26_ENFORCEMENT - M1977300
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2011-05-26_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:33:50 PM
Creation date
8/10/2011 2:35:59 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
5/26/2011
Doc Name
Reply Brief of Plaintiff Cotter Corporation (N.S.L.)
From
Cotter Corporation
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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Next, the Defendants contend that "the Order constitutes a cease and desist order despite <br />the lack of that specific language," but this assertion is also unpersuasive. Answer Brief at 57. <br />By this contention, the Defendants admit that the substantive provisions of the Order do not <br />contain the operative words "cease and desist." Further, the Defendants fail to show that the <br />Order constitutes a "cease- and - desist" order within the meaning of the Act. The plain language <br />of section 34 -32- 124(2) shows that a "cease- and - desist order" will order an operator to <br />"terminate" an "act" or "practice," such as a discharge to water. Colo. Rev. Stat. <br />§ 34- 32- 124(2)(a) ( "cease- and - desist order" shall set forth "the time by which the acts or <br />practices complained of must be terminated "). This construction of the statute is consistent with <br />the use of the term "cease- and - desist order" in section 34 -32 -122 of the Act. See Colo. Rev. <br />Stat. § 34- 32- 122(4)(c) (in circumstances justifying emergency response, Board may "[i]ssue a <br />written cease - and - desist order requiring any party to immediately discontinue an activity ") <br />(emphasis added). Moreover, the cases upon which the Defendants rely show that cease and <br />desist orders explicitly order a party to cease and desist various acts. See Precious Metals <br />Assoc., Inc. v. Commodity Futures Trading Comm'n, 620 F.2d 900, 902, 911 (1st Cir. 1980) <br />(agency ordered appellants to "cease and desist from the sale of options "); Hoving Corp., 290 <br />F.2d at 804 -05 (FTC ordered petitioner to "cease and desist" misbranding furs); People v. <br />Fremont Energy Corp., 651 P.2d 802, 808 (Wyo. 1982) (Wyoming DEQ may "include an order <br />to cease and desist from such alleged violation of the Act "). <br />Contrary to Defendants' assertions, see Answer Brief at 57, the Order is not a "cease -and- <br />desist order" within the meaning of the Act. The Order's recital that this matter came before the <br />authority to order corrective actions without first issuing a cease and desist order in compliance <br />with Colo. Rev. Stat. § 34- 32- 124(2)(a). As explained above, no such order was issued. <br />Accordingly, the issue is not one involving the agency's "discretion," but its compliance with <br />express statutory language. <br />42 <br />
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